Buchalter COVID-19 Client Alert: OCC Issues Final Rule Defining “True Lender” – A Bank is the “Lender” if it is Named the Lender in the Loan Documents or if it Funds the Loan
By EsqSocial Corporation 29/10/20
On October 27, the Office of the Comptroller of the Currency issued a final rule that establishes a new standard for when a national bank or Federal savings association (“bank”) is the “true lender” in a lending arrangement with a third party. This rule may have significant impact on bank’s partnerships and other arrangements with non-bank third parties, including bank-FinTech partnerships. It is particularly significant because, under the OCC’s recent rule regarding interest rate exportation...
By: Buchalter